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Given that the current expiration date for the temporary telehealth Medicare waivers is September 30, 2025, the telehealth field is curious to see if CMS would take a similar approach to how it handled the 2025 PFS, where several policies were introduced as a precautionary measure to mitigate the potential effects of an expiration to the temporary Medicare telehealth waivers. Below are highlights of the telehealth related items found in the CY 2026 PFS proposals. In addition to the below summary, today CCHP is releasing a newly created factsheet containing a more detailed analysis of the telehealth elements within the proposed 2026 PFS.
Eligible Services & Service Approval Process
The Medicare Telehealth Services List is the specific set of services for which Medicare will cover and reimburse when provided via telehealth. Typically, each year additional service(s) are added to the list (2025 Medicare Telehealth Services List). The services for addition to the list can be proposed by CMS itself, or the public can submit suggestions for additions to the list. For 2026, CMS is proposing to add the following to the eligible services list:
| HCPCS |
SHORT DESCRIPTION |
| 90849 |
Multiple family group psytx |
| G0473 |
Group behavioral counseling 2-10 |
| G0545 |
Inherent Visit to inpt |
| 92622 & 92623 |
Diagnostic analysis, programming and verification of an auditory osseointegrated sound processor |
Each year, CMS is also able to remove any services that are on the current year’s list. For CY 2026, they are proposing to remove G0136, which is the administration of a standardized, evidence-based social determinants of health risk assessment tool, 5 to 15 minutes. CMS is proposing the deletion of HCPCS code G0136 coverage generally for Medicare. CMS writes that the resource costs described in G0136 are already accounted for in existing codes.
This year, we also find that CMS is proposing to alter their current review process around how they determine which codes will be added to the eligible Telehealth Services List. Each proposed service currently goes through a five-step evaluation process – as a result of the five-step evaluation process, CMS then determines if the code should be denied from being on the list of eligible telehealth services in Medicare, or placed on the list in either a “permanent” or “provisional” status. The current five-step process involves the following:
- Determine whether the service is separately payable under the PFS.
- Determine whether the service is subject to the provisions of section 1834(m) of the Social Security Act.
- Review the elements of the service as described by the HCPCS code and determine whether each is capable of being furnished using an interactive telecommunications system as defined in 42 CFR § 410.78(a)(3).
- Consider whether the service elements of the requested service map to the service elements of services that are on the list with a permanent status described in previous final rulemaking.
- Consider whether there is evidence of clinical benefit analogous to the clinical benefit of the in-person service when the patient, who is located at a telehealth originating site, receives a service furnished by a physician or practitioner located at a distant site using an interactive telecommunications system.
CMS’ proposal in the 2026 proposed PFS suggests eliminating steps 4 and 5. CMS believes this change will help to streamline the process and make the method less confusing for those who wish to submit codes for potential addition to the Medicare Telehealth Services List.
Eliminating Frequency Limitations on Medicare Telehealth Subsequent Care Services in Inpatient and Nursing Facility Settings, and Critical Care Consultations
The frequency limitations (how often a service can be provided via telehealth) applicable to subsequent care services in inpatient and nursing facility settings, as well as critical care consultations, were initially waived during the COVID-19 public health emergency (PHE) and further suspended by CMS after the PHE ended. CMS stated that its analysis of claims data indicates the services are not currently being furnished via telehealth frequently enough to justify reimplementing limitations. Additionally, solicited comments from the public over the past two years have overwhelmingly supported permanently removing frequency limitations. For 2026, CMS is proposing to permanently remove frequency limitations on the following codes:
| HCPCS |
SHORT DESCRIPTION |
| 99231-99233 |
Subsequent Inpatient Visit CPT Codes |
| 99307-99310 |
Subsequent Nursing Facility Visit CPT Codes |
| G0508 & G0509 |
Critical Care Consultation Services: HCPCS Codes |
Federally Qualified Health Centers and Rural Health Clinics
In the current 2025 PFS, CMS extended federally qualified health centers (FQHCs) and rural health clinics (RHCs) ability to provide medical services via telecommunications technology through the end of 2025. This means that even if the current expiration date on the Medicare telehealth waivers comes to pass with no change and Medicare telehealth coverage reverts back to the permanent policies, FQHCs and RHCs will still be able to utilize telehealth to deliver medical services through the end of 2025. In the proposals for 2026, CMS is proposing to extend the same policy for another year. If the proposal is finalized, FQHCs and RHCs will be allowed to continue to use telecommunications technology to deliver medical services through December 31, 2026, no matter what may happen with the federal Medicare telehealth waivers. FQHCs and RHCs will receive a rate based on the current year’s fee schedule as opposed to their regular prospective payment system (PPS) or all-inclusive rate (AIR). It is important to also note that, several years back in the PFS, CMS also made a permanent change to FQHCs and RHCs ability to use telecommunications technology to provide mental health services by changing the definition of what a “mental health visit” meant for these entities.
Ambulatory Specialty Model (ASM)
The Ambulatory Specialty Model (ASM) is a new model that focuses on low back pain and congestive heart failure. The goal of the model is to prevent worsening or reoccurrence of chronic conditions, and improve chronic disease management and early detection. CMS’ overview of this model can be found in the Ambulatory Specialty Model factsheet. Under this model, certain permanent Medicare telehealth policies would be waived, namely the geographic and site requirements.
Additional Proposals
Some of the other proposals made in the 2026 PFS include:
- Telehealth originating site fee will be $31.85.
- Expands Digital Mental Health Treatment (DMHT) payment for DMHT devices that are approved for the treatment of Attention Deficit Hyperactivity Disorder (ADHD).
- New codes have been created for both Remote Therapeutic Monitoring (RTM) and Remote Physiological Monitoring (RPM) for less than 16 days of data transmission per 30 day period and less than 20 minutes of interactive communication per month.
- Several definition changes to the Medicare Diabetes Prevention Program (MDPP) that would extend virtual delivery flexibilities through to December 31, 2029.
- CMS is proposing to add coverage for asynchronous online delivery of MDPP through December 31, 2029.
- Permanent adoption of the definition of “immediate availability” of a supervising practitioner to include using audio-video real-time communication technology (audio-only is excluded) for certain services.
- CMS not to extend current direct supervision policy allowing teaching physicians to have a virtual presence for resident services furnished virtually (rural exceptions apply).
The proposed 2026 PFS provides a mixed bag for telehealth. Some of the proposals address requests that the telehealth community has long asked be made, such as the permanent waiver of frequency limits on certain services, while other proposals narrow the breadth of the policies from their broader version seen during the PHE/post-PHE landscape (i.e. the direct supervision of residents). One must keep in mind that CMS is limited in what it can do in regard to some of the other policies that impact the utilization of telehealth in Medicare, such as geographic and site limitations, which are policies embedded in federal statute. However, it is interesting to see that some of the more intriguing possibilities that were raised in the 2025 PFS, were not acted upon in these proposals for 2026. For example, in the 2025 PFS proposals, CMS requested feedback around including live video in the definition of a “visit” for FQHCs and RHCs. The proposal is similar to the one CMS made previously when they redefined “mental health visit” for these entities. Instead of making that definition change for 2026, CMS opted to propose just a one-year extension of FQHCs and RHCs’ ability to use telecommunications technology to provide medical visits.
Additionally, we see that an important policy to most telehealth providers was conspicuously missing from the proposed 2026 PFS. Upon review of the 2026 proposals, we do not find any mention of extending the allowance for distant site providers to use their currently enrolled practice location instead of their home address when enrolling to provide Medicare telehealth services from the home. Telehealth providers cite privacy and safety concerns, as reporting information such as their home address can mean that it is accessible by the public. Providers have long requested that accommodations be made for telehealth providers’ home address information to be protected. While the address reporting allowance was included in the final CY 2025 PFS, without the inclusion of an extension proposal within the CY 2026 PFS, this allowance will end January 1, 2026. |
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Comments are due to CMS by September 12, 2025. Electronic submissions: Federal RegisterRegular mail: Centers for Medicare & Medicaid Services, Department of Health and Human Services, Attention: CMS-1832-P, P.O. Box 8016, Baltimore, MD 21244-8016 Express mail: Centers for Medicare & Medicaid Services, Department of Health and Human Services, Attention: CMS-1832-P, Mail Stop C4-26-05, 7500 Security Boulevard, Baltimore, MD 21244-1850.
Commentors are encouraged to get their comments in before the deadline and if mailing to provide ample time to account for postal delivery. More detailed information on the proposed 2026 PFS can be found in CCHP’s Fact Sheet.See the original resource at : https://www.cchpca.org/resources/the-proposed-cy-2026-physician-fee-schedule-breaking-down-the-telehealth-elements/
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